NC0089621_Comments_20180830

August 30, 2018 novozymes®
Rethink Tomorrow
Via U.S. Mail and E-Mail
Jeffrey Poupart
Water Quality Permitting Section Chief
NCDEQ - Division of Water Resources
1611 Mail Service Center
Raleigh, North Carolina 27699-1611
[e-mail]
Julie Grzyb
Supervisor, Complex Permitting Unit
NCDEQ - Division of Water Resources
1611 Mail Service Center
Raleigh, North Carolina 27699-1611 SEP NRI®WR
[e-mail] 0 2018
water
CompleTeresa x Permitting ng Unit ez �ermittit9 Section
NCDEQ - Division of Water Resources
1611 Mail Service Center
Raleigh, North Carolina 27699-1611
[e-mail]
Mike Templeton
Water Quality Permitting Section
NCDEQ - Division of Water Resources
1611 Mail Service Center
Raleigh, North Carolina 27699-1611
[e-mail]
RE: NPDES Permit Application NC0089621
Novozymes North America, Inc.
Franklin County
Dear Mr. Poupart, Ms. Grzyb, Ms. Rodriguez, and Mr. Templeton:
Thank you very much for your time on Friday, August 24, 2018 to meet with the team from
Novozymes North America, Inc. ("Novozymes") and discuss NPDES Permit Application
NC0089621 (the "Permit Application"), by which Novozymes seeks authorization to treat and
discharge to surface waters up to two million gallons of wastewater per day (2 MGD). As noted
at the conclusion of our meeting last Friday, this letter provides some additional background
regarding Novozymes and the Permit Application and summarizes the main points of our
meeting.
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novozymes®
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Background
Novozymes is a global biotechnology company that makes commercial enzymes and biological
products used in a wide variety of commercial sectors, including baking, brewing, textiles,
renewable energy, detergent, aquaculture, and wastewater treatment. Locally, Novozymes is
the largest private employer in Franklin County with approximately 660 manufacturing jobs with
excellent benefits in a county that is 85% rural. The company is based in Denmark and is
known for its use of triple-bottom-line accounting which evaluates not just financial, but also
social and environmental metrics that are important to the company's core values.' Operating in
Franklinton since 1979, Novozymes makes enzymes using a fermentation process that
generates wastewater that is treated on-site and then either sprayed on farm fields near the
facility or discharged to the Franklin County POTW.
On May 31, 2016, Novozymes submitted the Permit Application for three important reasons.
First, the NPDES permit would create a conjunctive wastewater system whereby Novozymes
could employ three different wastewater disposal methods: (i) discharge to the Franklin County
POTW; (ii) land application to farm fields; and (iii) direct discharge. This conjunctive system will
give the plant much needed operational flexibility and wastewater flows can be adjusted
seasonally. Second, the NPDES permit will allow Novozymes to expand the Franklinton facility
and add more jobs in the manufacturing sector. Unfortunately, in 2017, the Franklinton facility
lost out on a large expansion project due to lack of progress on the Permit Application. Third,
the NPDES permit is required pursuant to the company's groundwater Corrective Action Plan
("CAP") for Incident Number 86545 related to Permits WQ0002806 and WQ0003487 that has
been approved by the Director of Division of Water Resources (the "Division"). Thus, the permit
is a prerequisite to moving forward with the approved CAP for groundwater, and Novozymes is
eager to proceed with full CAP implementation. The Permit Application has now been pending
with the Division for nearly 27 months.
Meeting on August 24
Novozymes requested the meeting last Friday with Division staff with the stated goals to define
the outstanding issues related to the Permit Application, to establish an agreed-upon path for
I See https.//www.novozymes.com/en/about-us/sustainability
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resolution of the outstanding issues, and to establish a general timeline for issuance of a draft
permit. Novozymes and the Division agreed that the three primary outstanding issues for
resolution are: (1) an appropriate permit limit for potassium in Novozymes effluent;
(2) completion of an analysis of best available technology economically achievable ("BAT") for
nutrient removal to develop an appropriate permit limit for Total Nitrogen (TN) and Total
Phosphorus (TP); and (3) review of modeling data to support a proposed outfall location on
Cedar Creek instead of the Tar River as originally proposed in the Permit Application. These
points are discussed below.
1. Potassium
As noted in Novozymes's letter dated July 24, 2018 and as discussed in our meeting last week,
Novozymes understands the Division's concerns regarding potassium, and Novozymes is
evaluating reverse osmosis ("RO") wastewater treatment technology as a solution. Novozymes
is in the middle of a pilot test of an RO system, and the initial results are promising. The pilot
testing should be completed in approximately six weeks. If RO is feasible for the facility,
Novozymes will install an RO system in conjunction with a final NPDES permit. RO should be a
game-changer for the Permit Application.
Regarding potential potassium permit limits, the Division and Novozymes agreed that, in
consultation with the DWR-Standards Branch, Novozymes will finalize and submit a report from
Ramboll Group that will provide chronic and acute aquatic life standards for potassium. If
acceptable to the Standards Branch, these standards could then be the basis for any necessary
potassium controls in the NPDES permit.
2. Analysis of Best Available Technology Economically Achievable for Nutrients
The Division previously requested that Novozymes conduct a BAT analysis to determine permit
limits for TN and TP. Novozymes submitted a BAT Analysis in 2017 and then a BAT Addendum
in 2018 incorporating additional information requested by the Division, including results of
treatability testing. In its June 19, 2018 letter, the Division again requested more information for
the BAT analysis. In our meeting, Novozymes requested certainty regarding the criteria and
protocol for the BAT analysis, and the Division agreed that was appropriate. To that end,
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Novozymes has scheduled a meeting on September 5, 2018 with Teresa Rodriguez and Mike
Templeton to finalize agreed-upon BAT analysis protocol.
3. Discharge Point at Cedar Creek
As discussed in our meeting last week, Novozymes proposes to amend the Permit Application
to change the proposed outfall location to Cedar Creek instead of the Tar River as originally
proposed in 2016. Novozymes has conducted dissolved oxygen modeling for Cedar Creek
indicating that it is a viable receiving stream. Novozymes and the Division agreed that
Novozymes will submit the modeling report and data to the DWR - Modeling & Assessment
Branch, and if the modeling is satisfactory, then Cedar Creek will be the outfall location.
Novozymes requested a 7Q10 determination from USGS South Atlantic Water Science Center
for the proposed discharge location at Cedar Creek having latitude/longitude coordinates
36.073863, -78.397628. The 7Q10 for this point was determined to be "from about 2.4 to 2.7
cfs (average and median about 2.4 cfs)." The USGS determination is enclosed for your
reference.
Next Steps and Action Items
As agreed at the meeting, the next steps toward issuance of a draft permit are the following:
• Ramboll Group and Novozymes will finalize and submit a report to the DWR-Standards
Branch that provides acute and chronic aquatic life standards for potassium.
• Novozymes will complete RO pilot testing and a feasibility assessment of RO as a
wastewater treatment technology.
• Novozymes will compile and update the BAT analysis pursuant to the protocol to be
agreed-upon on September 5, 2018 by Mike Templeton, Teresa Rodriguez, and
Novozymes.
• Novozymes will coordinate with Adugna Kebede from the DWR - Modeling &
Assessment Branch for review of the Cedar Creek QUAL2K water quality model.
• Novozymes will update the Engineering Alternatives Analysis to include information
regarding RO as part of the treatment system, if feasible, and discharge to Cedar Creek.
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• For ease of review by the Division, Novozymes will prepare a new application package
indicating the discharge location at Cedar Creek, the Division will consider the new
application package as submitted on the date of the original Permit Application, and the
package will maintain its same order of priority.
Timing
By e-mail dated July 27, 2018, the Division granted Novozymes's request for an extension of
time to 60 days after completion of the RO pilot test and feasibility review to provide the
requested additional information. This should be sufficient, and Novozymes plans to provide the
information as soon as possible.
Thank you again for your time and efforts regarding review and processing of the Permit
Application. Please let us know if there is anything you would like to add or clarify regarding the
contents of this summary of the meeting from August 24, 2018. We look forward to working with
the Division toward issuance of a draft NPDES permit.
Sincerely,
6)19_20
Angela J. Walsh
Novozymes North America, Inc.
Enclosure
cc: Bill Lane, DEQ General Counsel
Linda Culpepper, Division of Water Resources Director
Mary Penny Kelley, Special Advisor, Office of the Governor
Andrew Hargrove, DEQ Assistant General Counsel
Jeff Manning, Classifications, Standards & Rules Review Branch
Connie Brower, Classifications, Standards & Rules Review Branch
Chris Ventaloro, Classifications, Standards & Rules Review Branch
Adugna Kebede, Modelling &Assessment Branch
Bing Bai, Complex Permitting Unit
Rick Bolich, DWR- Raleigh Regional Office
Steve Tedder, Tedderfarm Consulting
Katie Jones, Dewberry
Mike Poulios, Dewberry
(all via e-mail only with enclosure)
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ANWA (Angela Walsh)
From: Weaver,John <[e-mail]>
Sent: Wednesday,August 22, 2018 12:29 PM
To: ANWA(Angela Walsh)
Cc: Steve Tedder;John C Weaver
Subject: Response from USGS concerning...Re: [EXTERNAL] Flow determination request
RECEIVED/DENR/DWR
SEP052018
Ms. Walsh, Water Resources
Permitting Section
In response to your inquiry about the low-flow characteristics(7Q10,30Q2,average annual discharge)for(1)Cedar Creek upstream from
Secondary Road 1114(Peach Orchard Road)and for(2)Tar River downstream from U.S.Highway 401 at Louisburg in central Franklin
County,the following information is provided:
For streams in Franklin County,low-flow characteristics published by the USGS are provided in the following reports:
(1)The first is a statewide report completed in the early 1990's. It is USGS Water-Supply Paper 2403,"Low-flow characteristics of streams
in North Carolina"(Giese and Mason, 1993). An online version of the report is available at http://pubs.usgs.gov/wsp/2403/report.pdf. The
report provides the low-flow characteristics(based on data through 1988)via regional relations and at-site values for sites with drainage
basins between 1 and 400 sqmi and not considered or known to be affected by regulation and/or diversions.
(2)The second is a statewide report published in March 2015. It is USGS Scientific Investigations Report 2015-5001,"Low-flow
characteristics and flow-duration statistics for selected USGS continuous-record streamgaging stations in North Carolina through 2012"
(Weaver,2015). The report is available online at http://pubs.usgs.gov/sir/2015/5001/. The report provides updated low-flow characteristics
and flow-duration statistics for 266 active(as of 2012 water year)and discontinued streamgages across the state where a minimum
of 10 climatic years discharge records were available for flow analyses.
Cedar Creek
A check of the low-flow files here at the USGS South Atlantic Water Science Center(Raleigh office)does not indicate a previous low-flow
determination for the specific point of interest,as identified by the lat/long coordinates(36.073863,-78.397628)provided in your email dated
August 15,2018. However,low-flow characteristics have been estimated at nearby locations within the Cedar Creek basin based on transfer
of low-flow characteristics from nearby partial-record and continuous-record sites within or near the basin.
No USGS discharge records are known to exist for the point of interest.
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,
In the absence of site-specific discharge records sufficient for a low-flow analysis,estimates of low-flow characteristics at ungaged locations
are determined by assessing a range in the low-flow yields(expressed as flow per square mile drainage area,or cfsm)at nearby sites where
such estimates have previously been determined.
A basin delineation completed using the online USGS StreamStats application for North Carolina
(http://water.usgs.gov/osw/streamstats/north carolina.html)indicates the drainage area for the point of interest(36.07379,-78.39761
NAD83)is 33.6 sqmi.
Inspection of the above two reports indicates the presence of four(4)selected nearby USGS partial-record sites(3)and continuous-record
streamgages(1)in general vicinity of the point of interest where low-flow characteristics were published. Among the 4 sites,one of the
partial-record sites(station id 02081770,drainage area 11.9 sqmi)and the continuous-record streamgage(station id 02081800,drainage area
47.8 sqmi)are located upstream and downstream,respectively,of the point of interest on Cedar Creek. Among these 2 sites,the low-flow
discharge yields for the indicated flow statistics are as follows:
Annual 7Q10 low-flow yields=>from 0.07 to 0.08 cfsm(average and median about 0.07 cfsm)
Annual 30Q2 low-flow yields=>from 0.3 to 0.34 cfsm(average and median 0.32 cfsm)
Average annual discharge yields=>from 1 to 1.05 cfsm(average and median about 1.03 cfsm)
Application of the above yield ranges to the drainage area(33.6 sqmi)for the point of interest results in the following estimated
low-flow discharges.
Annual 7Q10 discharges=>from about 2.4 to 2.7 cfs(average and median about 2.4 cfs)
Annual 30Q2 discharges=>from 10.1 to 11.4 cfs(average and median about 10.8 cfs)
Average annual discharge=>from 33.6 to 35.3 cfs(average and median about 34.6 cfs)
Tar River
A check of the low-flow files here at the USGS South Atlantic Water Science Center(Raleigh office)indicates a previous low-flow
determination for the location almost identical to the specific point of interest,as identified by the lat/long coordinates(36.086493,-
78.292017)provided in your email dated August 15,2018. Completed in January 1986,the low-flow characteristics were estimated for this
location(station id 02081757)below Fox Creek based on transfer of low-flow characteristics from nearby continuous-record streamgages on
the Tar River.
No USGS discharge records are known to exist for the point of interest.
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In the absence of site-specific discharge records sufficient for a low-flow analysis,estimates of low-flow characteristics at ungaged locations
are determined by assessing a range in the low-flow yields(expressed as flow per square mile drainage area,or cfsm)at nearby sites where
such estimates have previously been determined.
A basin delineation completed using the online USGS StreamStats application for North Carolina
(http://water.usgs.gov/osw/streamstats/north carolina.html)indicates the drainage area for the point of interest(36.08649,-78.29200
NAD83)is 446 sqmi.
There is a USGS continuous-record streamgage USGS Sta.02081747 Tar River at U.S.401 at Louisburg(drainage area 427 sqmi)located
about 0.5 mile upstream from the point of interest. This streamgage has continuous records of discharge(for all ranges of discharge)since
October 1972. The most recent low-flow statistics published for this streamgage are available in the second above-referenced report
(Weaver,2015). The low-flow yields for the 7Q10 and 30Q2 low-flow discharges(Table 3 on page 20 of this report,based on period of
record during the 1974-2011 climatic years)are as follows:
Annual 7Q10=0.0156 cfsm
Annual 30Q2=0.0821 cfsm
Average annual discharge yield=1.05 cfsm
Note:The climatic year is the standard annual period used in low-flow analyses for continuous-record streamgages and is from April 1
through March 31,designated by the year in which the period begins. For example,the 2011 climatic year is from April 1,2011,through
March 31,2012.
Application of the above yields to the drainage area(446 sqmi)for the point of interest results in the following estimated discharges:
Annual 7Q10=7.0 cfs
Annual 30Q2=36.6 cfs
Average annual discharge yield=468 cfs
Please note the estimated flows are provided in units of cubic feet per second(cfs).
Please note:The 1Q10 low-flow discharges for the points of interest also were requested in your email dated August 15,2018. The 1Q10
discharge is not among the low-flow statistics available within the standard scope of USGS responses to low-flow requests. There is
currently no cost-recovery fees applied to USGS responses to low-flow requests received by this office at this time. Additional analyses and
turnaround time would be required for the determination of 1Q10 low-flow characteristics,but would be limited to continuous-record
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streamgages with sufficient period of record for low-flow analyses. If you still require the 1Q10 discharge for the streamgage on the Tar
River at Louisburg,please let me know and we will proceed from there,as appropriate.
Please understand the information provided in this message is based on a preliminary assessment and considered provisional,subject to
revision pending further analyses.
Hope this information is helpful.
Thank you.
Curtis Weaver
5. Curtis Weaver, Hydrologist, PE Email: icweaverusas.aov
USGS South Atlantic Water Science Center Online:httns://www.usgs.00v/centers/sa-water
North Carolina-South Carolina-Georgia
3916 Sunset Ridge Road
Raleigh,NC 27607
Phone:[phone] // Fax:[phone]
On Wed, Aug 15,2018 at 1:48 PM,ANWA(Angela Walsh) <[e-mail]>wrote:
Mr.Weaver,
I hope this email finds you well.Steve Tedder provided me with your contact information and I was hoping you might
be able to help with some flow determinations. I am looking for 7Q10 and 1Q10 determinations for two stream
locations (approximate GPS coordinates for areas of interest are below). Please let me know if there's anything else
need to provide that would help with my request.
Cedar Creek:36.073863,-78.397628
Tar River:36.086493,-78.292017
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Best regards,
Angela Walsh,PE
Mgr-Environmental&Utilities Operations
Novozymes North America Inc.
PO BOX 576
77 Perrys Chapel Church Road
NC 27525 Franklinton United States
Phone: [phone]
} Mobile:[phone]
E-mail: [e-mail]
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